Dirty money still has an address: Unveiling the Opacity in Real Estate Ownership Index

Luxury flats overlooking Hyde Park. Waterfront villas in Miami. Skyscrapers rising from the desert in Dubai. For criminals and the corrupt, real estate remains the investment of choice and the perfect safety deposit box to stash dirty money.

Despite years of pledges from the world’s most powerful economies to crack down on money laundering, a new index has found that property markets are still shockingly exposed.

The first-ever Opacity in Real Estate Ownership (OREO) Index, released by Transparency International and the Anti-Corruption Data Collective (ACDC), assesses 24 jurisdictions – including G20 heavyweights and global financial hubs such as Singapore and Hong Kong – and finds that in most countries, money launderers can easily exploit loopholes, hide their identities and invest in real estate with little to no scrutiny. Even in high-performing countries, gaps in regulation and data transparency mean suspicious funds could continue to flow through the market undetected.

The inaugural OREO Index ranks how well some of the world’s largest economies and key financial hubs are protecting their property markets from dirty money.

Not a single country achieved a perfect score. Ten scored below five out of ten – suggesting wide-open doors for illicit funds.

The best performer? South Africa, which earned top marks for its regulatory framework and detailed property records. But even there, major flaws remain: data access is restricted to citizens, which could frustrate cross-border investigations, and recent reforms are yet to be fully implemented.

Other high scorers include Singapore, France and England & Wales. But all have outstanding loopholes to fix.

At the bottom of the table: Australia, South Korea and the United States. In all three, anti-money laundering regulation for real estate professionals is either non-existent or dangerously limited.

The OREO Index reveals that most jurisdictions still fail to collect or share the kind of ownership data needed to keep dirty money out of real estate.

Almost none record information on beneficial owners – the actual people behind companies or trusts that own real estate. Even where legal ownership is captured, data is often fragmented across systems, hard to access, or not available in machine-readable formats – making analysis and cross-matching with other datasets difficult.

Five countries – Argentina, China, Germany, Türkiye and the UAE – keep their real estate registers shielded from public view, accessible only to authorities, select professionals, users with ‘legitimate interest’ or the owners of the property. Others throw up major hurdles: in South Africa, opening a search account requires extensive documentation; in Mexico, data is inconsistently digitised across states; in Canada, access often comes with hefty subscription fees.

Even where data exists, it often lacks key details. Purchase prices and information on the intermediaries involved in the transaction like brokers or lawyers are frequently missing – making it harder to flag undervalued deals or suspicious financing.

Critically, almost no country provides real estate data that is fully open – free, bulk-downloadable and licensed for reuse. England & Wales and France are rare exceptions, offering bulk access to company-owned property records. But even here, linking ownership data to beneficial ownership or company registers remains difficult.

The result? Investigators, watchdogs and law enforcement face serious obstacles in tracing illicit funds through property markets. Without full, accessible and interoperable data, uncovering corrupt ownership patterns becomes a guessing game – one that too often favours the corrupt.

It’s not just the lack of transparency that enables dirty money to flood into global property markets – it’s how easily real estate deals can dodge scrutiny altogether. The OREO Index lays bare that corrupt actors can exploit gaps in anti-money laundering frameworks to buy and sell property with near impunity.

In several countries – including Australia, China, England & Wales, Japan and the UAE – real estate transactions can occur without any mandatory involvement from professionals subject to anti-money laundering obligations. That means property can change hands without a lawyer, agent or notary being legally required to ask who the buyer is or where their money comes from.

Many countries impose anti-money laundering obligations on some property professionals but leave entire categories – like developers – outside the scope. In Argentina, France, Hong Kong, Italy, Norway and the UAE, developers can sell property and housing projects directly without facing checks. In Brazil and Canada, lawyers aren’t covered by national anti-money laundering laws, and in Panama they are shielded from reporting suspicious transactions due to client confidentiality.

Supervision is also often weak or fragmented. In Germany, for example, oversight of anti-money laundering compliance by non-financial sector professionals is split between more than 300 different supervisors, making consistent enforcement challenging. In other countries, professional self-regulatory bodies are left to police their own members – with often unsatisfactory results.

Some jurisdictions still allow high-value real estate deals to be completed in cash, gold or even cryptocurrency, bypassing the banking system altogether. Only three countries – France, Hong Kong and the UAE – require payments for high-risk transactions to go through financial institutions. Others, like Germany, ban certain forms of real estate payments altogether, but such rules remain the exception.

And while due diligence rules are supposed to be stricter when high-risk clients – such as politically exposed persons – are involved, the reality is that many professionals either don’t apply the rules or don’t know how. In South Africa, Financial Action Task Force (FATF) evaluators found that legal professionals lacked awareness of the risks, even though they were covered by anti-money laundering laws.

All of this adds up to a simple truth: without robust oversight and real accountability, the corrupt can slip through the cracks.

Enhancing transparency of companies and real estate is crucial for detecting the inflow of dirty funds in the property markets. At the same time, real estate transactions must be subject to third-party scrutiny and professional service providers involved in the sale or purchase of properties should have anti-money laundering obligations. Without implementing both measures simultaneously, opacity will persist, allowing illicit activities to thrive unchecked.

To stop real estate from being used as a haven for illicit wealth, governments need to take bold action on three fronts: ownership transparency, regulation of enablers and data accessibility.

While some countries have made progress in recent years, reform remains piecemeal, and loopholes persist.

The G20 countries – many of whom are the worst offenders on the index – have previously committed to improving beneficial ownership transparency and combatting money laundering through real estate. They must now follow through: they should agree on a series of new commitments and hold each other accountable for putting them in practice. FATF, as the global standard-setter, should also explore issuing dedicated recommendations or guidance on transparency in the real estate sector.

Without a coordinated, global push, the world’s real estate markets will remain wide open to abuse. The question won’t be whether dirty money is in the market – but how much and who’s paying the real price.